VAFFC jet fuel vs Ministries of Environment

On the YVR jet fuel facilities project issue, the conservation and food security aspects are important to me (as on the Garden City Lands issue). My concerns escalated when I read the federal input from the federal environment and health ministries and the provincial input from the Ministry of Environment. It’s all transparently available on the provincial Environmental Assessment Office (EAO) website.

This article focuses on the proposed port facility near the Riverport area of Richmond, B.C., on the South Arm of the Fraser River Estuary.

The fuel delivery vessels would include huge Panamax tankers, designed to just squeeze in and out of the locks of the Panama Canal. The photos in this article show Panamax tankers.


Environment Canada (EC) concerns

The federal critiques identify a number of significant shortcomings in the project in a constructive way. For instance, an August 2011 letter from Environment Canada repeatedly offers to collaborate with the Vancouver Airport Fuel Facilities Corporation (VAFFC) to address the shortcomings.  Here’s the federal summary of concerns that Environment Canada has “consistently expressed”:

  • The Project would present a new and unacceptable risk to the locally, nationally and internationally important fish and wildlife populations of the Fraser River Estuary, including migratory birds and species at risk;
  • There exists a high level of uncertainty, due to the lack of credible, peer-reviewed science, regarding the potential effects of acute and chronic Jet-A fuel to migratory birds and their associated habitats, including biofilm; and
  • Based on its mandate for, and operational experience with responding to environmental emergencies, Environment Canada is of the opinion that there is limited ability with currently available technologies to effectively control a potential Jet-A fuel spill in the Fraser River Estuary.
    (all quoted from page 2 of the EC letter)

Environment Canada had expressed those concerns in a working group meeting involving VAFFC (“the proponent”) in early April 2010. Ten months later, there is no indication of progress on Environmental Canada’s urgent call for collaborative action.

Details of Environment Canada concerns

In a very clear and restrained way, the letter adds twelve more pages of detailed points. Here are a few that stood out for me:

  • “Environment Canada does not have the same confidence as the proponent in a spill response plan to effectively and reliably protect the high ecological values and sensitivities of the Fraser River Estuary” (quote from the EC letter).
  • Environment Canada inquires “how introducing Panamax class tankers into the Fraser River Estuary would reduce overall shipping risk.” (The hint of incredulity is expressed ever so politely.)
  • Environment Canada refutes the “proponent’s argument that there would be no spills of any kind” and “the proponent’s risk assessment generally for pipeline spills to a body of water.” It explains that “Under ideal conditions spill recovery is challenging, with inevitable loss of product” and that the “dynamic nature of the Fraser River” is not ideal conditions.
  • Environment Canada adds that “no amount of professional opinion can replace the existing and significant science gaps on the pathways and effects of Jet-A fuel on the receiving environment.”
  • Environment Canada says VAFFC “has failed to acknowledge” that the ecological effects of a spill “could extend across years, not just days, weeks and months.”
  • Environment Canada repeatedly attempts to convey “the extreme importance of the ecosystem at risk” and that lack of scientific evidence on key questions that have not been scientifically studied does not mean that there is no risk.
  • Environment Canada repeatedly shows that supposed evidence from VAFFC does not prove what it supposedly does. For instance, “The references presented and case studies cited . . . have little or no relevance to potential toxicological outcomes that could occur in the event of a spill in the Fraser River specifically.”

In the conclusion, “Environment Canada advises that the ecological risks of the proposal remain too great. Environment Canada emphasizes the need for credible, scientific data based on a comprehensive suite of studies designed to address the uncertainties addressed in this letter, including monitoring and empirical testing.”


Provincial Ministry of Environment concerns

The provincial Ministry of Environment response is consistent with that of Environment Canada, its federal counterpart.  That is evident in the September 2011 letter from the provincial Environmental Assessment Office, which is insistent that basic scientific studies that have not been done must be done.

The provincial letter also further rebuts the VAFFC assumptions that it could easily use oil booms to contain the spills that it believes will never happen. It states: “One final point at this time is that the term ‘containment’ should only be applied when the spilled material is completely contained including airspace (i.e. in a closed container). Flammable liquids spilled into waterways and encircled by oil booms do not constitute containment because they are discharging to the air.”


What’s next?

The non-existent scientific studies that should have been done prior to the application would take months. Despite a lengthy suspension, the 180-day limit for the Environmental Review will be reached on 24 April 2012, although it can be drawn out further. The review would be a travesty if the Environmental Assessment Office were to go along with the application at the current review-completion date.

In any event, the proposal would still have to be approved by the British Columbia’s Minister of the Environment (Hon. Terry Lake) and another minister, presumably the Minister of Transportation and Infrastructure (Hon. Blair Lekstrom).

From a public-input standpoint, focusing on that eventual step may be the effective approach. If VAFFC realizes that it will not get approval of its tanker-port proposal without genuinely ensuring environmental protection of the estuary, it may have the business sense to pursue relatively responsible alternatives.

Notes: In my recent letter on this topic in the Richmond News, I felt the need to be minimal. I mentioned “the ecological health of the estuary,” and this post fills out why that aspect of the jet fuel issue seems especially important to me. Also be aware that this article builds on five previous articles on this blog on the jet fuel proposal, going back to April 2010, and that a citizens’ group called VAPOR is taking a leading role in addressing the issue, along with Richmond council.


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